Deloitte last week published a report asserting banks and regulated financial service businesses in Asia need to be more than reactive to money laundering issues. The report posits firms in the future will be judged using a philosophy that if they could have known about a money laundering problem then they should have known. This would mean the days of passive anti-money laundering (AML) practices would be over.

In 2019, U.S. and U.K. regulators imposed a financial penalty in excess of $1 billion against Standard Chartered Bank for money laundering failures and sanctions breaches. Within the enforcement notices the regulators referenced failures related to the bank’s “reactive anti-money laundering program.”